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regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
Entities connected to both United States District Court and U.S. TaxExempt

United States
LOCATION
U.S. Virgin Islands
LOCATIONthe District of Massachusetts
LOCATIONthe First Circuit
ORGANIZATIONInvestment Concentration
ORGANIZATIONGlendower
LOCATIONthe District of Columbia
LOCATION
Eric Holder
PERSONCalder
ORGANIZATION
United Kingdom
LOCATION
Puerto Rico
LOCATION
Cyprus
LOCATION
Denmark
LOCATION
Lithuania
LOCATIONCity of New York
LOCATION
Ireland
LOCATION
Fidelity
ORGANIZATION
Slovakia
LOCATION
Belgium
LOCATION
Liechtenstein
LOCATION